How has the special rule for foreign pooled investment vehicles changed?

Under the special rule, a foreign pooled investment vehicle (PIV) meeting certain requirements has not been required to report information about all its beneficial owners to FinCEN, but only information about a single individual who exercises substantial control over the entity. The interim final rule amends the special rule so that, if the only individuals exercising such control over a foreign PIV are U.S. persons, no one’s information must be reported to FinCEN. If, however, more than one individual exercises substantial control over the foreign PIV and at least one of those individuals is not a U.S. person, the PIV must report the information of the non-U.S. person who has the greatest authority over the strategic management of the entity to FinCEN.